Colin Guinn emails out a 333 Exemption Template, but..

[Nimbus Ninja]

After his latest webinar, Colin sent out an email with some great links and resources. One of them being a template for the 333 Exemption. I read every line and learned a lot. I replaced all the yellow highlights with the appropriate information and explained in detail my specific use case. I already have an LLC for my business, I'm adding drone liability, and crossing all the my T's and dotting the I's. I just want to do what I already do, a little higher off the ground. 95 feet AGL.. Maybe..

I know laws are changing left and right, @EyeWingsuit provided some fantastic insight on the 333 exemption and the direction of Part 107, I feel like I've done my homework but.. when I went to file the exemption, I see the screen below. So my question is.. is all of this for nothing if I don't have any sort of pilots license? Nor do I have anyone on my team who I can peg as the PIC who would have that license.

If this is not the case and I've been asleep through "333 Exemption 101", I must have missed it in my homework and rightfully I need to start over, probably by finding someone with a pilots license or waiting for Part 107

 

[STMPNGRND]

Have you created your operating manual? That is the biggest piece of the process. Everyone submits theirs as private proprietary knowledge therefore they do not show up in the FAA 333 searchable database.

 

[Nimbus Ninja]

Have you created your operating manual? That is the biggest piece of the process. Everyone submits theirs as private proprietary knowledge therefore they do not show up in the FAA 333 searchable database.

You're making me feel really dumb lol. I didn't know about the operating manual. I'm glad you brought it up, but I'm assuming you are not trying to answer my question above about the pilots license. Or.. maybe you're saying that by submitting my Operating Manual, I will be able to circumvent the need for the pilots license.

Either way, clearly I cannot submit this yet without my operators manual. Let the googling begin.

I'll start that after I finish reading this one
Is Flying a Drone Illegal? A Comprehensive Guide to America’s Drone Laws

 

[STMPNGRND]

No way to get around the airman certificate requirement for PIC other than working the system and getting the lowest cert available which is for a balloon pilot. Most are just getting sport certificates which cost about half in terms of time and money to a private pilot cert.

Your 333 will be approved or denied on the strength of your ops manual. The template Colin sent out is just the nice form letter spelling out which regs you seek relief. Your ops manual will show how your planned operation mitigates the risk of waiving those regs.

When your 333 is granted, your activities will be bound by your ops plan. If you have an FAA reportable incident and you are found to have operated outside compliance of your plan your can get fines on every point of your plan you did not follow. You ops plan is essentially the regulation you are seeking to be bound by aside from the blanket points the FAA includes in all the approved 333s

The rub with ops plans are that if you make it too simple your petition will be denied or the process will be dragged out as the FAA will continue to seek additional info from you until they have enough to approve or deny. If you have a very in depth and robust plan then you will be approved faster and on the first try..however you are setting yourself up to have to follow that plan moving forward. How much paper work, record keeping and structure do you want to burden yourself with?

I would wait for some movement on part 107 before filing for a 333. One issue no one is talking about is what happens if and when part 107 becomes an official rule? A 333 is a company asset while part 107 is pilot based compliance. Will 333 holding companies or individuals still be bound by their terms? Will an approved drone operator under part 107 be allowed as a PIC in a 333 operation? If the 333s live on will certain industries require them over a part 107 operator? Guidelines set by insurance companies drive many policies of various industries. I spent 20 years in the Ski Industry. Integrating drone use in ski resort ops was pretty much eliminated by the 2 insurance companies that cover most of the industry more so than the decisions of resorts operators to do so.

 

[STMPNGRND]

here are some basic outlines that can get you pointed in the right direction to formulate your own drone operations manual..these are very basic and about all you can find via google. Most are private company assets that cost many hours and $$$ to develop and treated as such

https://www.caa.co.uk/WorkArea/DownloadAsset.aspx?id=4294975606
http://www.suasnews.com/wp-content/uploads/2012/11/UAS-Operations-Manual.pdf
http://www.suasnews.com/wp-content/uploads/2012/11/UAS-Operations-Manual.pdf
http://www.suasnews.com/wp-content/uploads/2012/11/UAS-Operations-Manual.pdf
http://skyviewaerialsolutions.com/wp-content/uploads/2016/01/UAS-Operations-Manual-Template.docx

 

[Nimbus Ninja]

here are some basic outlines that can get you pointed in the right direction to formulate your own drone operations manual..these are very basic and about all you can find via google. Most are private company assets that cost many hours and $$$ to develop and treated as such

https://www.caa.co.uk/WorkArea/DownloadAsset.aspx?id=4294975606
http://www.suasnews.com/wp-content/uploads/2012/11/UAS-Operations-Manual.pdf
http://skyviewaerialsolutions.com/wp-content/uploads/2016/01/UAS-Operations-Manual-Template.docx

Sharing is caring! Thanks!

 

[STMPNGRND]

you will also need all available manufacturer documentation for all the equipment you will be flying.

 

[jibcamera]

am I the only libertarian leaning person on these forums who sees all this as total horseshyte?

 

[STMPNGRND]

am I the only libertarian leaning person on these forums who sees all this as total horseshyte?

Nope...it is all BS. There is no law on the matter only an interpretation by the NTSB that model aircraft are aircraft and FAA is the overload of all aircraft in the NAS. But they have gotten their way by feeding the media hysteria and scared various industries to only hire those with 333.

 

[Nimbus Ninja]

I've decided to forego any 333 exemption. I don't mind putting in the work, but the FAA needs to get their shit together and then I'll play by a clear, concise set of rules that actually make sense. If I take a couple photos here and there and include them in any sold materials, I'll take that risk.

 

[STMPNGRND]

I've decided to forego any 333 exemption. I don't mind putting in the work, but the FAA needs to get their shit together and then I'll play by a clear, concise set of rules that actually make sense. If I take a couple photos here and there and include them in any sold materials, I'll take that risk.

One thing that may be wise to pass the time is to study for the written exam. Approximately 80% of the part 107 knowledge test will (supposedly) pertain to the basics of airspace and communication covered by ground school. It will get you one step closer in the meantime and either way the regs go you will need that knowledge. Plenty of info on the web as well as online classes for around $200

 

[Nimbus Ninja]

One thing that may be wise to pass the time is to study for the written exam. Approximately 80% of the part 107 knowledge test will (supposedly) pertain to the basics of airspace and communication covered by ground school. It will get you one step closer in the meantime and either the regs go will will need that knowledge. Plenty of info on the web as well as online classes for around $200

Good point. I think either way that would be time well spent

 

[EyeWingsuit]

One thing that may be wise to pass the time is to study for the written exam. Approximately 80% of the part 107 knowledge test will (supposedly) pertain to the basics of airspace and communication covered by ground school. It will get you one step closer in the meantime and either way the regs go you will need that knowledge. Plenty of info on the web as well as online classes for around $200

Nah...no need to spend $200.00 for the online courses; the Sportys.com Study Buddy for PPL has all you'll need. It's 9.99

 

[Nimbus Ninja]

Even better! I just want the info, I'll do the work

 

[EyeWingsuit]

I have privately shared my MPTOM with a few people on here; please forgive me for not sharing if I don't know you. I'm happy to share with people that I "know" from this community; it's a matter of private information being posted around the web and people copy/pasting ours/mine.

The resources above are pretty good; if you are really stumped, please p.m. me and I'll attempt to help you.

 

[STMPNGRND]

Nah...no need to spend $200.00 for the online courses; the Sportys.com Study Buddy for PPL has all you'll need. It's 9.99

How does the study buddy differ from their $199 online course?

 

[EyeWingsuit]

How does the study buddy differ from their $199 online course?

The Study Buddy is not nearly as in-depth, and doesn't have the interactive teaching mechanisms. The Study Buddy has flashcards, testing, and information, but doesn't give you the manuals. I'd recommend the 10.00 purchase and if you find yourself struggling, move up to the 200.00 option.

 

[Han Solo]

So glad this topic popped up this week, since I too was filling in Colin Guin's 333 application thinking that was all that was needed. As usual, nothing is as easy and cheap as I would think. Great info to dig into. Thanks guys!